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Anti-Bribery and Anti-Corruption Policy

SUMMARY

Dialectica LTD (the “Company”) operates in the Expert Network industry and recognized that its success depends heavily on its integrity, as well as the trust and confidence of its clientele. The Company is committed and conducts its business with respect to the highest ethical standards and precludes any act that could be promoted as bribery or corrupt. The Anti-Bribery and Anti-Corruption Policy (the “ABAC Policy”) prohibits all forms of bribery of government officials (globally) and private sector professionals, including but not limited to the offering, promising, authorizing or providing anything of value to any Client (current or provisional), Expert, or any third party in order to reward or induce the unethical performance of an activity connected with our business. Violation of the ABAC Policy potentially results in disciplinary actions that could include termination of employment. Hence, it is crucial to acknowledge, appreciate, and comply with the ABAC Policy in the aim of making our industry a safer place to conduct business.

This policy’s aim is to outline the Company’s approach to bribery and corruption and to highlight the responsibilities under the Company’s Policy and the relevant Anti-Corruption Laws, as well as to provide the necessary understanding to combat corruption risks. In addition, Dialectica holds all its company personnel to the highest ethical standard, and trains them on Anti-Bribery and Anti-Corruption legislations and regulations across all jurisdictions that Dialectica operates in.

WHAT IS BRIBERY? 

Bribery, which is considered a form of corruption, is the offering, promising, giving and/or accepting, or soliciting, directly or not, of any financial or other (non-pecuniary, tangible or intangible) valuable offering(s), with the intent to influence or reward an individual holding a position of trust in the aim of attempting or executing an act that would constitute to a commercial advantage. Bribery includes any form of attempt to perform any of the foregoing, even if the bribery act does not happen or even result in the anticipated advantage, the attempt is sufficient to constitute bribery.

WHO DOES THIS POLICY APPLY TO?

This policy applies to all the employees and personnel of all levels on a global basis. The Company expects transparency and integrity from its employees and personnel and demands them not to engage or be a part of any form of bribery or corruption regardless of citizenship or jurisdiction. We expect everyone at Dialectica to promote and exercise the optimum level of respect towards the upheld standards towards this criminal act. Dialectica’s Client Protection and Legal team is well equipped and trained to monitor and handle all business interactions in the aim of maintaining a compliant operating framework and environment. Dialectica’s Compliance Director is responsible for implementing and monitoring the policy and the company’s management team is responsible for ensuring the proper application of the policy by their team members.

OUR ZERO-TOLERANCE APPROACH

Given Dialectica’s zero-tolerance approach to all forms of Corruption in general, and Bribery in specific, the company encourages all employees, of all levels, to not give, accept, or attempt to give or accept any payment, gift, or gesture in bad faith in the aim of executing any activity that would be deemed uncompliant to this policy. In addition, this policy prohibits the facilitation of payments or any sort of kickbacks; employees and personnel of Dialectica are instructed and trained to avoid any of the abovementioned acts.  

WHAT COULD BE PERMITTED?

Within the parameters of international legislation and this policy, gifts, as well as other forms of hospitality, are common gestures provided as tokens of appreciation. Dialectica will allow tokens of that nature as long as they are provided in good faith, within reason, and compliant with its internal policies and guidelines. Company personnel will ensure that any gift’s value will be in proportion to the situation in question and not often. 

EMPLOYEE RESPONSIBILITIES, REPORTING, AND WHISTLEBLOWING

Dialectica’s employees acknowledge the cruciality of Corruption and Bribery. The information  provided within this policy will not be amended or changed in any shape or manner during gift-giving season or during the planning of any of the company’s events. In addition, employees are encouraged to notify their supervisors and/or the Compliance and Legal Department as soon as a potential breach to this policy has been identified. On the other hand, all employees are requested to report or raise their concerns about any suspicion of any corrupt act, such as bribery, at the earliest stage possible. Dialectica will conduct the proper investigations accordingly and take the appropriate next steps. With respect to Whistleblowing, Dialectica will never threaten an employee with any repercussions if they decide to report or inform management or the compliance team about a suspicion they might have. Any whistleblower will have the choice of keeping their identity anonymous and Dialectica will commit to maintaining said anonymity.  

Violating anti-bribery and anti-corruption laws could result in severe civil and criminal repercussions, which could lead to reputational damages to the Company. Hence, a violation of this policy could constitute termination of employment.  

COMPLIANCE TRAINING

All current and new employees at Dialectica will receive compliance training on the subjects of Corruption and Bribery. The Compliance and Legal Department, together with representatives from the Human Resources Department, will conduct trainings which will highlight the importance and necessary framework to combat corruption and bribery as well as the proper approach to deal with situations that are (or might seem) corrupt in nature. The purpose of these trainings will be to keep employees on track and updated on Anti-Bribery and Anti-Corruption, as well as maintaining awareness and the importance of remaining diligent and transparent while conducting business.

If you have any question with respect to the ABAC Policy, do not hesitate to contact the Company’s Client Protection and Legal Department at